Greater Cambridge Local Plan: Proposed Submission

See representation attached. Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:
“3. Additionally, development will only be supported:
a. where it will not prejudice the comprehensive and coordinated development of the wider area, having regard to key local strategies and frameworks
b. where the development is based on clearly articulated and justified objectives and an appropriate level of coordination which may include strategies and/or other over-arching coordination documents;
c. in instances where the infrastructure provision is to be phased, the development demonstrates that it is possible to be delivered in a timely and appropriate manner”
This alternative approach retains the Council’s objective of coordinated development while ensuring that the policy remains flexible, proportionate, and deliverable. It avoids placing unreasonable obligations on individual landowners and better reflects the realities of development delivery in Cambridge and so better support the timely and effective delivery of the Areas of Major Change.

See representation attached for Policy S/AMC: Cambridge Areas of Major Change.
On behalf of our client, Railpen, we submit the following representation in response to the emerging Local Plan policy wording relating to Areas of Major Change. The wording as currently drafted is provided below:

Part 3:
“3. Additionally, development will only be supported:
a. where it is in accordance with a comprehensive implementation plan for the area which has demonstrable support from all key landowners, or it is supported by evidence to demonstrate that the comprehensive and successful delivery of the development can still take place without this being secured;
b. where the development is based on clearly articulated and justified objectives and approach through the provision of a site-wide masterplan, strategies and/or other over-arching coordination documents;
c. in instances where the infrastructure provision is to be phased, an approved phasing strategy is in place.”

Response to part a and b (Comprehensive implementation plan and landowner support)
Railpen supports the principle of coordinated development and recognises the importance of comprehensive planning in appropriate circumstances. However, the additional criteria set out in points (a)–(c) impose unnecessary and disproportionate requirements that risk undermining the deliverability, flexibility, and effectiveness to deliver schemes at development sites. The policy does not acknowledge that different sites are at different stages; some yet to come forward through planning and some are already very advanced. For example, the Beehive Centre has a recent planning permission with extensive coordinating documents within it. There is no need or benefit to now suggest a new requirement on the Beehive Centre to provide documents to directly address parts a of the policy.

Response to part c (mandatory phasing strategy)
The blanket requirement for a site-wide masterplan and associated coordination documents is not proportionate in all circumstances. The policy fails to distinguish between large, complex, multi-landowner regeneration areas and sites where incremental or phased development is entirely appropriate. This approach risks over-prescription, reducing flexibility and responsiveness to market conditions and evolving delivery opportunities. The requirement for an approved phasing strategy wherever infrastructure provision is phased is unnecessarily restrictive. Phasing can change over time and may not be precisely know at such an early stage in the development process. Phasing is important but requiring approval of a phasing strategy at an early stage may constrain otherwise viable schemes and introduce avoidable delay. The policy should instead require at least an indicative phasing strategy to show how a site is capable of timely phasing, but not suggest a binding strategy is required to early in the process.

Summary of why Railpen consider the plan is not legally compliant or is unsound
The policy is considered unsound because it is overly prescriptive, insufficiently justified and may undermine effective delivery. It imposes blanket requirements for implementation plans, site-wide masterplans and phasing strategies without recognising differing site circumstances or stages of delivery. This could duplicate work already undertaken for advanced or consented sites, such as the Beehive Centre, while unnecessarily constraining incremental development. The requirements may reduce flexibility, delay delivery and restrict the ability of schemes to respond to changing market conditions. A more proportionate approach should focus on securing coordinated development and timely infrastructure delivery, with requirements tailored to individual site circumstances.

Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:
“3. Additionally, development will only be supported:
a. where it will not prejudice the comprehensive and coordinated development of the wider area, having regard to key local strategies and frameworks
b. where the development is based on clearly articulated and justified objectives and an appropriate level of coordination which may include strategies and/or other over-arching coordination documents;
c. in instances where the infrastructure provision is to be phased, the development demonstrates that it is possible to be delivered in a timely and appropriate manner”
This alternative approach retains the Council’s objective of coordinated development while ensuring that the policy remains flexible, proportionate, and deliverable. It avoids placing unreasonable obligations on individual landowners and better reflects the realities of development delivery in Cambridge and so better support the timely and effective delivery of the Areas of Major Change.

Railpen suggests amendments to the wording of Policy S/AMC/BC part 1 (a). The wording as currently drafted is provided below:
“1. Development proposals across this policy area, will be supported if they:
a. Create a positive, balanced and attractive environment, to support the successful regeneration of the site and its integration with the surrounding area to support the vitality and viability of this area;

Response to part a:
The intention and practical application of this criterion is unclear. The terms “vitality and viability” (part a) are well-established planning concepts, most commonly used in the assessment of town centre and retail uses. As currently drafted, the criterion risks creating uncertainty and ambiguity for decision-makers and applicants, particularly given the scale and mixed-use nature of the proposed redevelopment. While ‘vitality and viability’ have a strong foundation in retail policy, the policy (and the extant planning permission for the site) is to reduce/remove the amount of retail floorspace. Policies should be sufficiently precise to provide clarity and certainty, particularly where they are intended to guide large-scale, long-term redevelopment.
Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:
“Development proposals across this policy area, will be supported if they
a. Create a positive, balanced and attractive environment, to support the successful regeneration of the site and its integration with the surrounding area;

Response to Part 2:
Railpen suggests amendments to the wording of Policy S/AMC/BC part 2 (a and b). The wording as currently drafted is provided below:
Any proposals to reconfigure the retail park to provide alternative uses must include:
a. “A clear set of development and environmental objectives and overarching development and environmental strategy framework to guide the site’s re configuration over the short, medium and long-term; and
b. a material improvement in the quality of the site’s environment and public realm to support the overall vitality and viability of the area. This should include providing external plant equipment to support outdoor cultural activities”
Response to part a:
As drafted, the requirement for an “overarching development and environmental strategy framework” lacks clarity and precision. The term is undefined within the Local Plan and does not correspond to any commonly recognised planning document, which creates uncertainty for applicants and decision-makers as to its scope, content, level of detail, and status within the decision-making process. This ambiguity risks placing an open-ended and potentially onerous burden on development proposals, contrary to the requirement for planning policies to be clear, justified and effective.

Response to part b:
The terms “vitality and viability” are well-established planning concepts, most commonly used in the assessment of town centre and retail uses. As currently drafted, the criterion risks creating uncertainty and ambiguity for decision-makers and applicants, particularly given the scale and mixed-use nature of the proposed redevelopment. While ‘vitality and viability’ have a strong foundation in retail policy, the policy (and the extant planning permission for the site) is to reduce/remove the amount of retail floorspace. Policies should be sufficiently precise to provide clarity and certainty, particularly where they are intended to guide large-scale, long-term redevelopment.
To improve clarity and ensure the policy better reflects the site’s strategic role and planned evolution, Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:
a. “A clear set of development and environmental objectives and overarching development and environmental strategy to guide the site’s re configuration over the short, medium and long-term; and
b. a material improvement in the quality of the site’s environment and public realm to support the overall of the area. This should include providing equipment to support outdoor cultural activities”

Response to part 3:
Railpen requests amendments to the wording of Policy S/AMC/BC part 3 (a). The wording as currently drafted is provided below:
Where feasible, proposals should:
a. create better east-west and north-south connections, improving the area’s links with the surrounding neighbourhoods;
The reference to east–west connections fail to acknowledge the presence of the railway line along the site’s eastern boundary. In addition, the future role of the Greater Cambridge Partnership is uncertain, and references to it should therefore be removed.
Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:
“Where feasible, proposals should:
a. Take opportunities to improve the connectivity with the surrounding neighbourhoods;

Response to Para 3.1.131
Railpen suggests amendments to the wording of Policy S/AMC/BC para 3.1.136, not least to acknowledge the important fact that the site received consent from the Secretary of State for the comprehensive redevelopment of the site. This is a material matter for the context of the policy and must be recognised that the consent defines that development and what is required from it.
Para 3.1.96 The former Beehive Centre area provides an important edge-of-centre brownfield site for intensification for a range of uses that complement the adjacent residential and retail park uses. This reconfiguration and intensification of uses affords the site many opportunities to improve its accessibility within the site and beyond, including access to Cambridge Retail Park which should be maximised to encourage the use of sustainable forms of transport to access the area and help reduce vehicular congestion. The area’s long-term strategy is also expected to improve the area’s environment and appeal for residents, local workers and visitors from further afield.
The policy does not adequately reflect the Secretary of State’s December 2025 decision granting planning permission for a comprehensive redevelopment of the site, which included a commercial R&D scheme, a new local centre, significant public realm improvements, a new public park, and enhanced connectivity. The applicant suggests the addition of the following wording after 3.1.96:
In December 2025, the Secretary of State granted planning permission for a comprehensive redevelopment of the site, comprising a commercial R&D-led scheme including a new local centre, significant public realm, a new public park and enhanced connectivity. That consented scheme is supported by approved phasing plans and a coordinated, site-wide approach to future development, which together meet the policy expectations for a Comprehensive Implementation Plan and an overarching development and environmental strategy framework.

Response to Para 3.1.98
Railpen suggests amendments to the wording of Policy S/AMC/BC para 3.1.132. The wording of this is shown below:
“All short-to-medium proposals should have regard for the site’s long-term ambition. Relevant public realm, landscape, movement and servicing strategies should consider how these have regard for these progressive stages and remain consistent with the area’s agreed overarching development and environmental strategy framework, to ensure a cohesive approach to the site’s comprehensive redevelopment.”
The reference to an “overarching development and environmental strategy framework” is unclear, as the policy does not define what it is, when it is required, or the purpose it is intended to serve, creating uncertainty for applicants and decision-makers. Railpen suggested the amended wording below:
“All short-to-medium proposals should have regard for the site’s long-term ambition. Relevant public realm, landscape, movement and servicing strategies should consider how these have regard for these progressive stages and remain consistent with the area’s agreed development and environmental requirements , to ensure a cohesive approach to the site’s comprehensive redevelopment.”

See representation attached for Policy S/AMC/BC: Beehive Centre
On behalf of our client, Railpen, we submit the following representation in response to the emerging Local Plan policy parts 1a, 2a, 2b, 3a and supporting paragraphs 3.1.131 and 3.1.132 wording relating to Policy S/AMC/BC: Beehive Centre.

Railpen suggests amendments to the wording of Policy S/AMC/BC part 1 (a). The wording as currently drafted is provided below:
“1. Development proposals across this policy area, will be supported if they:
a. Create a positive, balanced and attractive environment, to support the successful regeneration of the site and its integration with the surrounding area to support the vitality and viability of this area;

Response to part a:
The intention and practical application of this criterion is unclear. The terms “vitality and viability” (part a) are well-established planning concepts, most commonly used in the assessment of town centre and retail uses. As currently drafted, the criterion risks creating uncertainty and ambiguity for decision-makers and applicants, particularly given the scale and mixed-use nature of the proposed redevelopment. While ‘vitality and viability’ have a strong foundation in retail policy, the policy (and the extant planning permission for the site) is to reduce/remove the amount of retail floorspace. Policies should be sufficiently precise to provide clarity and certainty, particularly where they are intended to guide large-scale, long-term redevelopment.
Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:
“Development proposals across this policy area, will be supported if they
a. Create a positive, balanced and attractive environment, to support the successful regeneration of the site and its integration with the surrounding area;

Response to Part 2:
Railpen suggests amendments to the wording of Policy S/AMC/BC part 2 (a and b). The wording as currently drafted is provided below:
Any proposals to reconfigure the retail park to provide alternative uses must include:
a. “A clear set of development and environmental objectives and overarching development and environmental strategy framework to guide the site’s re configuration over the short, medium and long-term; and
b. a material improvement in the quality of the site’s environment and public realm to support the overall vitality and viability of the area. This should include providing external plant equipment to support outdoor cultural activities”
Response to part a:
As drafted, the requirement for an “overarching development and environmental strategy framework” lacks clarity and precision. The term is undefined within the Local Plan and does not correspond to any commonly recognised planning document, which creates uncertainty for applicants and decision-makers as to its scope, content, level of detail, and status within the decision-making process. This ambiguity risks placing an open-ended and potentially onerous burden on development proposals, contrary to the requirement for planning policies to be clear, justified and effective.

Response to part b:
The terms “vitality and viability” are well-established planning concepts, most commonly used in the assessment of town centre and retail uses. As currently drafted, the criterion risks creating uncertainty and ambiguity for decision-makers and applicants, particularly given the scale and mixed-use nature of the proposed redevelopment. While ‘vitality and viability’ have a strong foundation in retail policy, the policy (and the extant planning permission for the site) is to reduce/remove the amount of retail floorspace. Policies should be sufficiently precise to provide clarity and certainty, particularly where they are intended to guide large-scale, long-term redevelopment.
To improve clarity and ensure the policy better reflects the site’s strategic role and planned evolution, Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:
a. “A clear set of development and environmental objectives and overarching development and environmental strategy to guide the site’s re configuration over the short, medium and long-term; and
b. a material improvement in the quality of the site’s environment and public realm to support the overall of the area. This should include providing equipment to support outdoor cultural activities”

Response to part 3:
Railpen requests amendments to the wording of Policy S/AMC/BC part 3 (a). The wording as currently drafted is provided below:
Where feasible, proposals should:
a. create better east-west and north-south connections, improving the area’s links with the surrounding neighbourhoods;
The reference to east–west connections fail to acknowledge the presence of the railway line along the site’s eastern boundary. In addition, the future role of the Greater Cambridge Partnership is uncertain, and references to it should therefore be removed.
Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:
“Where feasible, proposals should:
a. Take opportunities to improve the connectivity with the surrounding neighbourhoods;

Response to Para 3.1.131
Railpen suggests amendments to the wording of Policy S/AMC/BC para 3.1.136, not least to acknowledge the important fact that the site received consent from the Secretary of State for the comprehensive redevelopment of the site. This is a material matter for the context of the policy and must be recognised that the consent defines that development and what is required from it.
Para 3.1.96 The former Beehive Centre area provides an important edge-of-centre brownfield site for intensification for a range of uses that complement the adjacent residential and retail park uses. This reconfiguration and intensification of uses affords the site many opportunities to improve its accessibility within the site and beyond, including access to Cambridge Retail Park which should be maximised to encourage the use of sustainable forms of transport to access the area and help reduce vehicular congestion. The area’s long-term strategy is also expected to improve the area’s environment and appeal for residents, local workers and visitors from further afield.
The policy does not adequately reflect the Secretary of State’s December 2025 decision granting planning permission for a comprehensive redevelopment of the site, which included a commercial R&D scheme, a new local centre, significant public realm improvements, a new public park, and enhanced connectivity. The applicant suggests the addition of the following wording after 3.1.96:
In December 2025, the Secretary of State granted planning permission for a comprehensive redevelopment of the site, comprising a commercial R&D-led scheme including a new local centre, significant public realm, a new public park and enhanced connectivity. That consented scheme is supported by approved phasing plans and a coordinated, site-wide approach to future development, which together meet the policy expectations for a Comprehensive Implementation Plan and an overarching development and environmental strategy framework.

Response to Para 3.1.98
Railpen suggests amendments to the wording of Policy S/AMC/BC para 3.1.132. The wording of this is shown below:
“All short-to-medium proposals should have regard for the site’s long-term ambition. Relevant public realm, landscape, movement and servicing strategies should consider how these have regard for these progressive stages and remain consistent with the area’s agreed overarching development and environmental strategy framework, to ensure a cohesive approach to the site’s comprehensive redevelopment.”
The reference to an “overarching development and environmental strategy framework” is unclear, as the policy does not define what it is, when it is required, or the purpose it is intended to serve, creating uncertainty for applicants and decision-makers. Railpen suggested the amended wording below:
“All short-to-medium proposals should have regard for the site’s long-term ambition. Relevant public realm, landscape, movement and servicing strategies should consider how these have regard for these progressive stages and remain consistent with the area’s agreed development and environmental requirements , to ensure a cohesive approach to the site’s comprehensive redevelopment.”

Summary of why Railpen consider the plan is not legally compliant or is unsound:
Railpen considers the policy unsound because several requirements are unclear, imprecise and insufficiently justified, creating uncertainty for applicants and decision-makers. References to “vitality and viability” are inappropriate in the context of a site transitioning away from predominantly retail uses, while the undefined “overarching development and environmental strategy framework” risks imposing an open-ended and disproportionate burden. The policy also fails to reflect physical constraints on connectivity and does not adequately acknowledge the Secretary of State’s December 2025 permission for comprehensive redevelopment of the Beehive Centre. Amendments are therefore required to ensure the policy is clear, effective, proportionate and properly reflects the site’s established planning context.

Response to part 5:
Railpen objects to the inclusion of the Beehive Centre in Policy J/RC part 5. The wording as currently drafted is provided below:
Across Greater Cambridge’s network of centres (including Cambridge City Centre but excluding the Primary Shopping Area), proposals that would result in the loss of any retail or other main town centre use or in the reconfiguration of separate planning units through the merging of two or more units or sub-division of a unit will only be supported where:
a. there is no market demand for the existing unit(s) or potential replacement unit(s) of the same size and use, as demonstrated through an up-to-date marketing exercise for at least 12 months in accordance with the guidance provided in Appendix G: Marketing, local needs assessments and viability appraisals of this Local Plan demonstrating that the premises are not reasonably capable of being used or redeveloped for a town centre use acceptable in the centre; or
b. evidence is submitted that demonstrates the new use or reconfiguration of planning units (through merger or sub-division) would:
i. meet an identified need for alternative community, retail or leisure facilities;
ii. contribute positively to the vitality, viability and diversity of the centre; and
iii. not result in significant adverse impacts on surrounding uses
The additional criteria set out in policy J/RC impose unnecessary and disproportionate requirements that risk undermining the deliverability, flexibility, and effectiveness of development on the Beehive Centre site – a site which is subject to its own site specific policy (S/AMC/BC: Beehive Centre) to seek a comprehensive redevelopment of it.
On behalf of our client, Railpen, we request that the Beehive Centre site is excluded from the list of designated Retail Centres in the Local Plan. Designating the site as a Retail Centre creates a direct policy conflict with the Council’s ambition to achieve a comprehensive, major redevelopment of the site, which includes a commercial R&D-led scheme, a new local centre, enhanced public realm, and improved connectivity.


Response to part 8c

Railpen suggests amendments to the wording of Policy J/RC part 8(c). The existing wording of policy 8(c) is shown below:
8. Proposals for retail and other main town centre uses outside designated centres will only be permitted where:

c. for retail and leisure proposals where the development exceeds 500 square metres of gross internal floorspace, the proposal is accompanied by a Town Centre Impact Assessment to demonstrate that there would be no significant adverse impacts on existing, committed and planned investment or on the vitality and viability of centres that may be affected.

500sqm is only a fifth of the national default of 2,500sqm (Policy TC4(1) NPPF 2026) for Impact Assessments, representing a significant departure from national policy. A threshold set this low will also draw a wide range of modest, everyday proposals, such as single convenience stores, restaurant or gym units, creating an onerous and expensive requirement for small retailers. As currently drafted, criterion 8(c) is exposed to challenge at Examination as unjustified and disproportionate. We request the Council either reinstate the national default threshold.

Railpen suggests that the wording of condition 8(c) is altered to the policy wording below:

8. Proposals for retail and other main town centre uses outside designated centres will only be permitted where:

c. for retail and leisure proposals where the development exceeds 2,500 square metres of gross internal floorspace, the proposal is accompanied by a Town Centre Impact Assessment, proportionate to the scale and nature of the proposal to demonstrate that there would be no significant adverse impacts on existing, committed and planned investment or on the vitality and viability of centres that may be affected.


Para 8.91
Railpen objects to the wording of para 8.91 related to Policy J/RC
The supporting text refers to certain restrictions that the Council might put in place to reduce the permitted development rights of a scheme in main town centres. Railpen objects to the policy, on the grounds that greater flexibility should be offered to avoid the potential for empty shop locations, enhance deliverability and align with the goals on flexibility within the NPPF and support the purposeful flexibility that led to Class E being introduced. We request that paragraph 8.91 is removed.

See representation attached for Policy J/RC: Retail and other complementary town centre uses
On behalf of our client, Railpen, we submit the following representation in response to the emerging Local Plan policy wording relating to Policy J/RC: Retail and other complementary town centre uses.
Response to part 5:
Railpen objects to the inclusion of the Beehive Centre in Policy J/RC part 5. The wording as currently drafted is provided below:
Across Greater Cambridge’s network of centres (including Cambridge City Centre but excluding the Primary Shopping Area), proposals that would result in the loss of any retail or other main town centre use or in the reconfiguration of separate planning units through the merging of two or more units or sub-division of a unit will only be supported where:
a. there is no market demand for the existing unit(s) or potential replacement unit(s) of the same size and use, as demonstrated through an up-to-date marketing exercise for at least 12 months in accordance with the guidance provided in Appendix G: Marketing, local needs assessments and viability appraisals of this Local Plan demonstrating that the premises are not reasonably capable of being used or redeveloped for a town centre use acceptable in the centre; or
b. evidence is submitted that demonstrates the new use or reconfiguration of planning units (through merger or sub-division) would:
i. meet an identified need for alternative community, retail or leisure facilities;
ii. contribute positively to the vitality, viability and diversity of the centre; and
iii. not result in significant adverse impacts on surrounding uses
The additional criteria set out in policy J/RC impose unnecessary and disproportionate requirements that risk undermining the deliverability, flexibility, and effectiveness of development on the Beehive Centre site – a site which is subject to its own site specific policy (S/AMC/BC: Beehive Centre) to seek a comprehensive redevelopment of it.
On behalf of our client, Railpen, we request that the Beehive Centre site is excluded from the list of designated Retail Centres in the Local Plan. Designating the site as a Retail Centre creates a direct policy conflict with the Council’s ambition to achieve a comprehensive, major redevelopment of the site, which includes a commercial R&D-led scheme, a new local centre, enhanced public realm, and improved connectivity.


Response to part 8c

Railpen suggests amendments to the wording of Policy J/RC part 8(c). The existing wording of policy 8(c) is shown below:
8. Proposals for retail and other main town centre uses outside designated centres will only be permitted where:

c. for retail and leisure proposals where the development exceeds 500 square metres of gross internal floorspace, the proposal is accompanied by a Town Centre Impact Assessment to demonstrate that there would be no significant adverse impacts on existing, committed and planned investment or on the vitality and viability of centres that may be affected.

500sqm is only a fifth of the national default of 2,500sqm (Policy TC4(1) NPPF 2026) for Impact Assessments, representing a significant departure from national policy. A threshold set this low will also draw a wide range of modest, everyday proposals, such as single convenience stores, restaurant or gym units, creating an onerous and expensive requirement for small retailers. As currently drafted, criterion 8(c) is exposed to challenge at Examination as unjustified and disproportionate. We request the Council either reinstate the national default threshold.

Railpen suggests that the wording of condition 8(c) is altered to the policy wording below:

8. Proposals for retail and other main town centre uses outside designated centres will only be permitted where:

c. for retail and leisure proposals where the development exceeds 2,500 square metres of gross internal floorspace, the proposal is accompanied by a Town Centre Impact Assessment, proportionate to the scale and nature of the proposal to demonstrate that there would be no significant adverse impacts on existing, committed and planned investment or on the vitality and viability of centres that may be affected.


Para 8.91
Railpen objects to the wording of para 8.91 related to Policy J/RC
The supporting text refers to certain restrictions that the Council might put in place to reduce the permitted development rights of a scheme in main town centres. Railpen objects to the policy, on the grounds that greater flexibility should be offered to avoid the potential for empty shop locations, enhance deliverability and align with the goals on flexibility within the NPPF and support the purposeful flexibility that led to Class E being introduced. We request that paragraph 8.91 is removed.

See representation attached for J/RC: RETAIL AND OTHER COMPLEMENTARY TOWN CENTRE USES.
On behalf of our client, Railpen, we submit an objection to part 5 (a and b) of emerging policy J/RC Retail and other Complementary Town Centre Uses.
Greater Cambridge emerging Local Plan Policy J/RC Part 5
Part 5: Across Greater Cambridge’s network of centres (including Cambridge City Centre but excluding the Primary Shopping Area), proposals that would result in the loss of any retail or other main town centre use or in the reconfiguration of separate planning units through the merging of two or more units or sub-division of a unit will only be supported where:
a. there is no market demand for the existing unit(s) or potential replacement unit(s) of the same size and use, as demonstrated through an up-to-date marketing exercise for at least 12 months in accordance with the guidance provided in Appendix G: Marketing, local needs assessments and viability appraisals of this Local Plan demonstrating that the premises are not reasonably capable of being used or redeveloped for a town centre use acceptable in the centre; or
b. evidence is submitted that demonstrates the new use or reconfiguration of planning units (through merger or sub-division) would:

i. meet an identified need for alternative community, retail or leisure facilities; 632
ii. contribute positively to the vitality, viability and diversity of the centre; and iii. not result in significant adverse impacts on surrounding uses.
Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:
Railpen requests that part 5 is removed to support the vitality and viability of retail centres and not have a policy position to act to have units vacant for some 12 months merely to fulfil a marketing period.

Hierarchy of Designated Centres
This includes Beehive Centre as a ‘District and Town Centre’; however, the Beehive Centre is to be an Area of Major Change, with its own policy to promote that change (S/AMC/BC) and has received in December 2025 planning consent for the complete redevelopment of the site which will remove much of the retail floorspace. It is peculiar and inappropriate to have two policies that so clearly act against each other: S/AMC/BC promoting change and J/RC inferring some protected status to its retail function. Railpen requests that the Beehive Centre is removed from the named list of Hierarchy of Designated Centres.

See representation attached for J/RC: RETAIL AND OTHER COMPLEMENTARY TOWN CENTRE USES.
On behalf of our client, Railpen, we submit an objection to part 5 (a and b) of emerging policy J/RC Retail and other Complementary Town Centre Uses.
Greater Cambridge emerging Local Plan Policy J/RC Part 5
Part 5: Across Greater Cambridge’s network of centres (including Cambridge City Centre but excluding the Primary Shopping Area), proposals that would result in the loss of any retail or other main town centre use or in the reconfiguration of separate planning units through the merging of two or more units or sub-division of a unit will only be supported where:
a. there is no market demand for the existing unit(s) or potential replacement unit(s) of the same size and use, as demonstrated through an up-to-date marketing exercise for at least 12 months in accordance with the guidance provided in Appendix G: Marketing, local needs assessments and viability appraisals of this Local Plan demonstrating that the premises are not reasonably capable of being used or redeveloped for a town centre use acceptable in the centre; or
b. evidence is submitted that demonstrates the new use or reconfiguration of planning units (through merger or sub-division) would:

i. meet an identified need for alternative community, retail or leisure facilities; 632
ii. contribute positively to the vitality, viability and diversity of the centre; and iii. not result in significant adverse impacts on surrounding uses.
Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:
Railpen requests that part 5 is removed to support the vitality and viability of retail centres and not have a policy position to act to have units vacant for some 12 months merely to fulfil a marketing period.

Hierarchy of Designated Centres
This includes Beehive Centre as a ‘District and Town Centre’; however, the Beehive Centre is to be an Area of Major Change, with its own policy to promote that change (S/AMC/BC) and has received in December 2025 planning consent for the complete redevelopment of the site which will remove much of the retail floorspace. It is peculiar and inappropriate to have two policies that so clearly act against each other: S/AMC/BC promoting change and J/RC inferring some protected status to its retail function. Railpen requests that the Beehive Centre is removed from the named list of Hierarchy of Designated Centres.

Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:
Part 3: Where proposals provide opportunities and potential challenges, site promoters should develop a policy framework steering document, approved by the planning authority as part of a planning application to promote and guide overall change during the life of the plan for the relevant area.
Para 3.1.121 It is recognised that while development can improve an area’s attractiveness it can also challenge the area’s character, in such circumstances site promoters are encouraged to develop a policy framework steering document to guide the area’s reconfiguration

See representation attached for Policy S/PRIA: Public Realm Improvement Areas (PRIA) in Cambridge
On behalf of our client, Railpen, we submit the following representation in response to the emerging Local Plan policy wording relating to Policy S/PRIA: Public Realm Improvement Areas (PRIA) in Cambridge.
Railpen suggests amendments to the wording of part 3 and para 3.1.156 of policy S/PRIA worded below:
Part 3 of Policy S/PRIA is worded as follows:
Part 3: Where proposals provide opportunities and potential challenges, site promoters should develop a policy framework, approved by the planning authority to promote and guide overall change during the life of the plan for the relevant area.
Paragraph 3.1.121 of Policy S/PRIA is worded as follows:
Para 3.1.121 It is recognised that while development can improve an area’s attractiveness it can also challenge the area’s character, in such circumstances site promoters are encouraged to develop a policy framework to guide the area’s reconfiguration

Summary of why Railpen consider the plan is not legally compliant or is unsound
We recommend that the wording be amended to refer instead to “steering document(s)”. This would achieve the same objective of guiding and coordinating change over the life of the plan, while providing a more practical, flexible and deliverable mechanism aligned with the comprehensive approach already established, such as at Cambridge Retail Park (CRP) and its already formed Framework Document. The content and full intentions of a policy framework is not clear but infers an unnecessary degree of additional policy layered over the Local Plan. It should also be made clearer when the suggested document would come forward, we request (if it is a policy requirement that is kept) that it is as part of a planning application.

Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:
Part 3: Where proposals provide opportunities and potential challenges, site promoters should develop a steering document, approved by the planning authority as part of a planning application to promote and guide overall change during the life of the plan for the relevant area.
Para 3.1.121 It is recognised that while development can improve an area’s attractiveness it can also challenge the area’s character, in such circumstances site promoters are encouraged to develop a steering document to guide the area’s reconfiguration

Railpen Supports the amended wording of Policy S/PRIA/CRP part 1 (a).

Railpen suggests amendments to the wording of part 2 (a and c) of policy S/PRIA/CRP worded below:
“Proposals to reconfigure the retail park to provide additional floorspace will include:
a. An overarching development and environmental strategy framework to guide the site’s re-configuration over the short, medium and long-term;
c. A better urban relationship with Newmarket Road, the Beehive Centre development and the surrounding neighbourhoods.”

We request that the reference to a “framework” be amended to refer instead to “steering document(s)”. This would achieve the same objective of guiding and coordinating change over the life of the plan, while providing a more practical, flexible and deliverable mechanism aligned with the comprehensive approach already established at Cambridge Retail Park (CRP) through is already formed Framework Document.

Railpen recommends that part c of the wording is amended to overcome the uncertainty for what an ‘urban relationship’ is and rather provide a clearer policy direction that any future application that comes forward will respond positively to the adjacent area.

Railpen suggests the amended wording, which is provided below:
“Proposals to reconfigure the retail park to provide additional floorspace will include:
a. An overarching development and steering document to guide the site’s re-configuration over the short, medium and long-term;
c. An improved design approach that responds positively to the adjacent areas”

Railpen suggests amendments to the wording of part 3(b and d) of policy S/PRIA/CRP worded below:
“where feasible proposals should:
b. Improve connectivity with surrounding neighbourhoods including creating better east-west and north-south connections, improving the area’s links with the surrounding neighbourhoods”
The reference to east–west connections fail to acknowledge the presence of the railway line along the site’s eastern boundary. The text should therefore be updated to read:
b. Improve connectivity with surrounding neighbourhoods including creating better connections, improving the area’s links with the surrounding neighbourhoods”


Railpen suggests amendments to the wording of part 4 of policy S/PRIA/CRP worded below:
Part 4: An urban design led approach should be taken to inform the appropriate scale and massing of development proposals in the policy area. Studies will also be required to justify proposed land uses floorspaces and their redevelopment on a proposal-by proposal basis.
Railpen suggests amendments to the wording of part 4 of policy S/PRIA/CRP, to incorporate a reference to a steering document. The suggested wording of part 4 is provided below:
Part 4: An urban design led approach should be taken to inform the appropriate scale and massing of development proposals in the policy area. Studies will also be required to show that land use proposals will be in accordance with the approved steering document on a proposal-by-proposal basis.

Supporting Information
Railpen requests amendments to the wording of para 3.1.125 of policy S/PRIA/CRP.
We recommend that the wording be amended to refer to a “steering document”. This would achieve the same objective of guiding and coordinating change over the life of the plan, while providing a more practical, flexible and deliverable mechanism aligned with the comprehensive approach already established, such as at Cambridge Retail Park (CRP) and its already formed Framework Document. The content and full intentions of a policy framework is not clear but infers an unnecessary degree of additional policy layered over the Local Plan.
The amended wording of para 3.1.125 is provided below:
para 3.1.125: It is, however recognised that the site is subject to many constraints related to the current leaseholders on site that may limit these opportunities, in the short-to-medium term. However, all short-to-medium proposals should have regard for the site’s long term ambition. Relevant public realm, landscape, movement and servicing strategies should consider how these have regard for these progressive stages and remain consistent with the area’s agreed overarching development and environmental strategy framework steering document, to ensure a cohesive approach to the park's evolution, ensuring it remains 'open for business' throughout.

See representation attached for Policy S/PRIA/CRP: Cambridge Retail Park (CRP)
On behalf of our client, Railpen, we submit the following representation in response to the emerging Local Plan policy wording relating to S/PRIA/CRP: Cambridge Retail Park (CRP).
Railpen Supports the amended wording of Policy S/PRIA/CRP part 1 (a).

Railpen suggests amendments to the wording of part 2 (a and c) of policy S/PRIA/CRP worded below:
“Proposals to reconfigure the retail park to provide additional floorspace will include:
a. An overarching development and environmental strategy framework to guide the site’s re-configuration over the short, medium and long-term;
c. A better urban relationship with Newmarket Road, the Beehive Centre development and the surrounding neighbourhoods.”

We request that the reference to a “framework” be amended to refer instead to “steering document(s)”. This would achieve the same objective of guiding and coordinating change over the life of the plan, while providing a more practical, flexible and deliverable mechanism aligned with the comprehensive approach already established at Cambridge Retail Park (CRP) through is already formed Framework Document.

Railpen recommends that part c of the wording is amended to overcome the uncertainty for what an ‘urban relationship’ is and rather provide a clearer policy direction that any future application that comes forward will respond positively to the adjacent area.

Railpen suggests the amended wording, which is provided below:
“Proposals to reconfigure the retail park to provide additional floorspace will include:
a. An overarching development and steering document to guide the site’s re-configuration over the short, medium and long-term;
c. An improved design approach that responds positively to the adjacent areas”

Railpen suggests amendments to the wording of part 3(b and d) of policy S/PRIA/CRP worded below:
“where feasible proposals should:
b. Improve connectivity with surrounding neighbourhoods including creating better east-west and north-south connections, improving the area’s links with the surrounding neighbourhoods”
The reference to east–west connections fail to acknowledge the presence of the railway line along the site’s eastern boundary. The text should therefore be updated to read:
b. Improve connectivity with surrounding neighbourhoods including creating better connections, improving the area’s links with the surrounding neighbourhoods”


Railpen suggests amendments to the wording of part 4 of policy S/PRIA/CRP worded below:
Part 4: An urban design led approach should be taken to inform the appropriate scale and massing of development proposals in the policy area. Studies will also be required to justify proposed land uses floorspaces and their redevelopment on a proposal-by proposal basis.
Railpen suggests amendments to the wording of part 4 of policy S/PRIA/CRP, to incorporate a reference to a steering document. The suggested wording of part 4 is provided below:
Part 4: An urban design led approach should be taken to inform the appropriate scale and massing of development proposals in the policy area. Studies will also be required to show that land use proposals will be in accordance with the approved steering document on a proposal-by-proposal basis.

Supporting Information
Railpen requests amendments to the wording of para 3.1.125 of policy S/PRIA/CRP.
We recommend that the wording be amended to refer to a “steering document”. This would achieve the same objective of guiding and coordinating change over the life of the plan, while providing a more practical, flexible and deliverable mechanism aligned with the comprehensive approach already established, such as at Cambridge Retail Park (CRP) and its already formed Framework Document. The content and full intentions of a policy framework is not clear but infers an unnecessary degree of additional policy layered over the Local Plan.
The amended wording of para 3.1.125 is provided below:
para 3.1.125: It is, however recognised that the site is subject to many constraints related to the current leaseholders on site that may limit these opportunities, in the short-to-medium term. However, all short-to-medium proposals should have regard for the site’s long term ambition. Relevant public realm, landscape, movement and servicing strategies should consider how these have regard for these progressive stages and remain consistent with the area’s agreed overarching development and environmental strategy framework steering document, to ensure a cohesive approach to the park's evolution, ensuring it remains 'open for business' throughout.

Summary of why Railpen consider the plan is not legally compliant or is unsound
Railpen's concern is that Policy S/PRIA/CRP, as drafted, will not be effective or justified. Requiring an "overarching development and environmental strategy framework" is seen as an impractical, inflexible mechanism unlikely to be deliverable, whereas a "steering document" would achieve the same coordinating purpose more flexibly. The requirement for a "better urban relationship" with surrounding areas is too vague to give applicants or decision-makers clear direction, undermining certainty. And the policy's reference to "east-west" connections is flawed, ignoring the railway line forming the site's eastern boundary. meaning these parts of the policy are not based on robust, proportionate evidence.

See representation attached. Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:
1. Development will meet the objectively assessed needs in Greater Cambridge over the period 2024-2045 for:
a. a minimum of 73,300 net additional jobs (against a 2024 baseline) to support the Greater Cambridge’s knowledge intensive sectors, and also provide a diverse range of local jobs; and
6. Where monitoring or updated economic evidence indicates that jobs growth in Greater Cambridge is tracking above, or is likely to exceed, the central forecast underpinning criterion 1(a), the Councils will support the timely identification of additional employment land, including through a partial or early review of this Plan, to meet that growth need.

See representation attached for Policy S/JH (New Jobs and Homes)
On behalf of our client, Railpen, we submit the following representation in response to policy S/JH part 1 (a and b) of the emerging Local Plan policy wording relating to new jobs and homes.
Railpen objects to Policy S/JH as unsound and considers its drafting raises legal compliance concerns under section 19(2) of the Planning and Compulsory Purchase Act 2004 (regard to national policy). The objection is tested against the four soundness tests set out in national planning policy: positively prepared, justified, effective, and consistent with national policy.
"73,300 additional jobs" is undefined. Policy S/JH(1)(a) requires development to meet "73,300 additional jobs to support…knowledge intensive sectors, and also provide a diverse range of local jobs," but states no baseline year and does not clarify whether the figure is net or gross, or a single combined total. A figure used to trigger monitoring action, and against which planning decisions may be tested, must be capable of consistent, objective interpretation (Tesco Stores v Dundee CC [2012] UKSC 13). As drafted, it is not, failing the Effective test).
The central, not the upper, growth scenario is the right basis for "need." The Employment and Housing Evidence Update 2025 (EHNU 2025) identifies both a "central" (c.3,500 jobs/year) and a higher forecast. Railpen objects to the Councils' reliance on the central scenario (para 2.10) and supports the upper growth scenario as the proportionate, evidence-based measure of objectively assessed need.
The figure must be a minimum, not a ceiling. Criterion 1(a) omits "minimum" for jobs. This is inconsistent with NPPF Policy S1(1)(a), which requires plans to meet objectively assessed needs for "housing, business and other uses…as a minimum," and risks the figure being applied in decision-taking as an upper bound against which further employment proposals could wrongly be resisted as unnecessary once 73,300 is reached." Policy S/JH(1)(a) should be modified to read "a minimum of 73,300 additional jobs."
The plan does not lodge the need for growth beyond current supply. Despite the plan acknowledging a greater level of flexibility built into the existing growth scenario (2.32), the policy still provides an overall cap on the growth of jobs which mitigates the ultimate flexibility that national policy seeks to achieve and is unrepresentative a city with growth ambitions that Cambridge has.
Without these changes, the plan is neither positively prepared, justified nor effective, and Railpen requests that Policy S/JH be modified accordingly.
Growth for Greater Cambridge is also set to be delivered by the Greater Cambridge Development Corporation (GCDC). A body that is now legally formed.
The approach of the LPA may be that the GCDC will deliver the growth over-and-above the minimum provision in the Draft Local Plan, but; the GCDC is yet to receive plan-making powers; it will prepare a Plan after the adoption of the Draft GCLP; it will need to undertake formal consultation and examination in public in the normal way to lead to a formally adopted “successor” Plan. Such a successor Plan will be many years away, while the growth ambition is now. The GCLP needs to address growth now and not rely on a possible GCDC Plan.
Summary of why Railpen consider the plan is not legally compliant or is unsound
Railpen considers Policy S/JH unsound and raises legal compliance concerns. The “73,300 additional jobs” figure is undefined, with no baseline or confirmation whether it is net, gross or a combined total, undermining effective monitoring and decision-making. The Councils’ central employment growth scenario is the appropriate evidence-based measure of need; the higher scenario should be treated as flexibility rather than requirement. The jobs figure should be expressed as “a minimum of 73,300” to avoid operating as a ceiling. The Plan should further acknowledge potential growth beyond identified capacity and provide a mechanism, such as allocations or early review, to accommodate it.
Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:
1. Development will meet the objectively assessed needs in Greater Cambridge over the period 2024-2045 for:
a. a minimum of 73,300 net additional jobs (against a 2024 baseline) to support the Greater Cambridge’s knowledge intensive sectors, and also provide a diverse range of local jobs; and
6. Where monitoring or updated economic evidence indicates that jobs growth in Greater Cambridge is tracking above, or is likely to exceed, the central forecast underpinning criterion 1(a), the Councils will support the timely identification of additional employment land, including through a partial or early review of this Plan, to meet that growth need.

See representation attached, Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:
Part 2:
To avoid the wastage of embodied carbon in existing buildings and to avoid the creation of new embodied carbon in replacement buildings, and proportionate to the scale and significance of the demolition proposed, there is a presumption in favour of repairing, refurbishing, and re-using existing buildings over their demolition. This presumption is applied as part of the overall planning balance and is not, of itself, a reason to refuse an otherwise acceptable proposal. Proposals that result in the demolition of a building (in whole or a significant part) should be accompanied by a full justification for the demolition. Compliance with criteria (a) to (d) below must be demonstrated through a Whole Life Carbon Assessment, prepared in accordance with the RICS methodology referred to in criterion 2(b), submitted with the application. Demolition will only be acceptable where it is demonstrated that:

Para 4.60
A significant proportion of a building’s whole-life greenhouse gas emissions are locked into its fabric, with emissions stemming from material manufacturing, the transportation of materials and components, and physical construction and demolition – these emissions are commonly referred to as “embodied carbon”. The effective application of circular economy principles to the built environment creates places where buildings are designed for adaptation, reconstruction and deconstruction, which reduces the need to extract raw materials and manufacture new building components. To avoid the unnecessary wastage of embodied carbon emissions in existing buildings, proposals must make every effort to refurbish, retrofit and re-use existing buildings and building materials, where possible. It is recognised that retrofit or refurbishment may not be the most sustainable option for the development of a site or may not be viable, but applicants must present a clear case that one or more of criteria (a) to (d) of Policy CC/CE is satisfied.

See representation attached for Policy CC/CE (Supporting a circular economy and sustainable resource use)
Railpen objects to Policy CC/CE as unsound and considers its drafting raises legal compliance concerns under section 19(2) of the Planning and Compulsory Purchase Act 2004 (regard to national policy). The objection is tested against the four soundness tests set out in national planning policy: positively prepared, justified, effective, and consistent with national policy.

Criterion 2 uses undefined, subjective terms. "Significant part" is not defined in the policy itself and supporting paragraph 4.64's glossary ("a proportion…with significant carbon content") is not a workable threshold. "To the satisfaction of the Local Planning Authority" imports pure discretion, with no objective evidential standard for an Applicant to work to. A test decision-makers, applicants and the Plan's own supporting text cannot apply consistently fails the effective test and the standard identified by Tesco Stores v Dundee CC [2012] UKSC 13.

NPPF policy S3/S4 sets the general decision-making standard that development should be approved unless adverse effects substantially outweigh the benefits. Policy CC/CE placing the burden on the applicant to satisfy a discretionary LPA-controlled test before demolition is even acceptable in principle, with wider benefits allowed only on an "exceptional basis." NPPF reserves that kind of heightened test for defined assets of particular importance e.g habitats sites, designated heritage. Applying an equivalent bar to Greater Cambridge, without site-specific justification, sits uneasily with the requirement that plan policies extending beyond site-specific matters be demonstrably necessary and justified, and fails to be Consistent with National Policy test.

Criterion (d) is the only route for wider benefits, but confines them to "exceptional" cases where they must "outweigh" carbon savings, rather than being weighed as part of the ordinary three-way balance of economic, social and environmental objectives that NPPF paragraph 17 requires to be pursued "in mutually supportive ways," not sequentially. As drafted, the policy does not allow proper weight to benefits such as housing and employment delivery, building safety, energy performance and design quality. Left unbalanced, Policy CC/CE also risks undermining delivery, a further Positively Prepared and Effective test concern.

Railpen requests that criterion 2, and in particular criterion (d), be reworded so wider sustainable development benefits are weighed in the normal way against embodied carbon savings, rather than confined to exceptional cases where they must outweigh them.

Summary of why Railpen consider the plan is not legally compliant or is unsound
Railpen considers Policy CC/CE unsound and potentially legally non-compliant because its wording is unclear, overly discretionary and inconsistent with national policy. Undefined terms such as “significant part” and reliance on what satisfies the LPA create uncertainty and undermine effectiveness. The policy also imposes a stricter presumption against demolition than the NPPF generally requires, without sufficient justification. By allowing wider development benefits to be considered only exceptionally, it creates an inappropriate hierarchy rather than balancing economic, social and environmental objectives. Railpen therefore seeks revised wording so embodied carbon savings are weighed proportionately against wider sustainable development benefits through the normal planning balance.

Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:
Part 2:
To avoid the wastage of embodied carbon in existing buildings and to avoid the creation of new embodied carbon in replacement buildings, and proportionate to the scale and significance of the demolition proposed, there is a presumption in favour of repairing, refurbishing, and re-using existing buildings over their demolition. This presumption is applied as part of the overall planning balance and is not, of itself, a reason to refuse an otherwise acceptable proposal. Proposals that result in the demolition of a building (in whole or a significant part) should be accompanied by a full justification for the demolition. Compliance with criteria (a) to (d) below must be demonstrated through a Whole Life Carbon Assessment, prepared in accordance with the RICS methodology referred to in criterion 2(b), submitted with the application. Demolition will only be acceptable where it is demonstrated that:

Para 4.60
A significant proportion of a building’s whole-life greenhouse gas emissions are locked into its fabric, with emissions stemming from material manufacturing, the transportation of materials and components, and physical construction and demolition – these emissions are commonly referred to as “embodied carbon”. The effective application of circular economy principles to the built environment creates places where buildings are designed for adaptation, reconstruction and deconstruction, which reduces the need to extract raw materials and manufacture new building components. To avoid the unnecessary wastage of embodied carbon emissions in existing buildings, proposals must make every effort to refurbish, retrofit and re-use existing buildings and building materials, where possible. It is recognised that retrofit or refurbishment may not be the most sustainable option for the development of a site or may not be viable, but applicants must present a clear case that one or more of criteria (a) to (d) of Policy CC/CE is satisfied.

See representation attached. 4. Proposals for residential sites of 200 or more dwellings (or groups of smaller sites which cumulatively exceed this figure) and employment development of over 5000 square metres must be informed by detailed assessments of both sports, recreation, culture and community needs proportionate to the number of net additional employees the development is reasonably expected to generate and include strategies that address identified needs relevant to the development proposal. Submitted strategies to meet community and cultural needs must demonstrate that the local community, and stakeholders have been engaged to guide the provision of community facilities to be introduced as part of the site-wide development strategy. Measures may be required to assist the development of a new community, such as through community development workers.
6. Contributions for community facilities will be based on a standard of 129 square metres of such floorspace per 1,000 additional population. Contributions for cultural facilities will be 100 square metres per 1,000 additional population and for commercial schemes a contribution proportionate to the evidenced net additional local demand arising from the specific development, up to a maximum of 1.5% of Net Internal Area commercial space. This is based upon a combination of the Arts Council England benchmark and Museums, Libraries and Archives (MLA) Standard applied to the local context (using the Department for Culture, Media and Sport Participation Survey). For all applicable proposals, Community and Cultural Plans will form part of the planning submission process and these must demonstrate a robust, evidence-led and locally responsive approach for their provision and long-term viability. All plans should: identify the needs generated by the proposal; detail the provision required including their specification and delivery schedule; and provide details about their funding, stewardship and monitoring, to ensure their successful imple
11. The cumulative requirements of this policy, taken together with other Local Plan policies, will not be applied where it is demonstrated that to do so would render a commercial development unviable

Please see representation attached for Policy WS/NC (Meeting the needs of new and growing Communities)
Railpen objects to Policy WS/NC as unsound and considers its drafting raises legal compliance concerns under section 19(2) of the Planning and Compulsory Purchase Act 2004 (regard to national policy). The objection is tested against the same four soundness tests as before: positively prepared, justified, effective, and consistent with national policy.

Criterion 4 requires "employment development of over 5,000 square metres" to be "informed by detailed assessments of both sports, recreation, culture and community needs, and include strategies that address identified needs," evidenced by demonstrated community and stakeholder engagement. This is a new procedural and evidential requirement imposed on commercial applicants for needs with a materially weaker link to office/R&D floorspace than to housing, without justification specific to commercial development.

Criteria 5–6 confirm contributions will be secured "through planning obligations or through a Community Infrastructure Levy (CIL) as appropriate," (CIL is not at the time of writing applicable in Cambridge) applying a standard of "100 square metres per 1,000 additional population and 1.5% of Net Internal Area commercial space", which is a flat floorspace-based levy on commercial development, unrelated to population growth, "secured through Section 106 agreements." Obligations of this kind must satisfy Regulation 122 of the CIL Regulations 2010, necessary, directly related to the development, and fairly and reasonably related in scale and kind. A flat percentage charge, untethered to demonstrated need, defies that test. Commercial schemes and the context they sit within varies significantly across Greater Cambridge, yet the policy is a blanket one-size-fits-all approach.

What a given commercial scheme will actually be required to fund turns on criteria 2–3's case-by-case "appropriate to the level of need" test, agreed "in consultation with service providers," with a further review and clawback mechanism (criterion 10) if viability later improves. NPPF policy PM13(1) requires quantitative development plan standards to "provide clarity and a high degree of certainty about the requirements that relevant development proposals are expected to meet." As drafted, WS/NC does not, which is an Effective test failing and a real impediment to land acquisitions.

Even set against Railpen's own strong amenity commitment in its schemes, requiring commercial floorspace to fund community development workers, cultural floorspace and sports facilities at this scale goes beyond what NPPF policy DM5 anticipates the plan-wide viability assessment tested, which must cover the specific development type in question. If commercial typologies were not robustly tested, WS/NC risks undermining delivery of Policy S/JH's own 73,300 jobs requirement.

Railpen requests that criterion 4's threshold and evidential burden for commercial schemes be reviewed, that criterion 6's commercial floorspace standard be justified against CIL Regulation 122 and withdrawn or evidenced if it cannot be, and that criteria 2–3 set objective, scheme-size-linked contribution bands to restore certainty for site appraisal.

Summary of why Railpen consider the plan is not legally compliant or is unsound
Railpen considers Policy WS/NC unsound and potentially legally non-compliant because it imposes unjustified and uncertain obligations on commercial development. Criterion 4 requires major employment schemes to assess and address community, cultural, recreation and sports needs despite a weaker relationship with commercial floorspace. Criteria 5–6 introduce a flat commercial contribution standard that may not satisfy CIL Regulation 122 requirements for necessity, direct relationship and proportionality. The policy also lacks certainty over contribution levels, undermining effective site appraisal and potentially development viability. Railpen therefore seeks clearer, evidence-based thresholds, justified commercial standards and objective, scheme-size-linked contribution bands to provide greater certainty for applicants.


Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:
4. Proposals for residential sites of 200 or more dwellings (or groups of smaller sites which cumulatively exceed this figure) and employment development of over 5000 square metres must be informed by detailed assessments of both sports, recreation, culture and community needs proportionate to the number of net additional employees the development is reasonably expected to generate and include strategies that address identified needs relevant to the development proposal. Submitted strategies to meet community and cultural needs must demonstrate that the local community, and stakeholders have been engaged to guide the provision of community facilities to be introduced as part of the site-wide development strategy. Measures may be required to assist the development of a new community, such as through community development workers.

6. Contributions for community facilities will be based on a standard of 129 square metres of such floorspace per 1,000 additional population. Contributions for cultural facilities will be 100 square metres per 1,000 additional population and for commercial schemes a contribution proportionate to the evidenced net additional local demand arising from the specific development, up to a maximum of 1.5% of Net Internal Area commercial space. This is based upon a combination of the Arts Council England benchmark and Museums, Libraries and Archives (MLA) Standard applied to the local context (using the Department for Culture, Media and Sport Participation Survey). For all applicable proposals, Community and Cultural Plans will form part of the planning submission process and these must demonstrate a robust, evidence-led and locally responsive approach for their provision and long-term viability. All plans should: identify the needs generated by the proposal; detail the provision required including their specification and delivery schedule; and provide details about their funding, stewardship and monitoring, to ensure their successful imple

11. The cumulative requirements of this policy, taken together with other Local Plan policies, will not be applied where it is demonstrated that to do so would render a commercial development unviable

Railpen recommends the removal of part 4 of the policy.

See representation attached for Policy BG/EO (Providing and enhancing open spaces)
Railpen principally supports the objective of providing and enhancing open space. However, it objects to the policy as drafted as it fails to adequately recognise the specific characteristics of commercial development within Greater Cambridge, particularly development located within established science parks and employment campuses.

Criterion 4 requires all commercial developments exceeding 2,000 sqm GIA to provide open space equivalent to 2.0 hectares per 1,000 employees. This requirement is overly prescriptive and risks undermining the efficient use of employment land. The 2,000 sqm threshold is low, and the blanket requirement for 20 sqm of open space per employee is unlikely to be appropriate across all development types and locations. In particular, schemes in more constrained urban locations may struggle to meet the requirement without comprising the efficient use of land and achieving development viability.  NPPF policy L1(1)(a)(iii) expects plans to actively identify through design-led, context-sensitive approaches rather than a blanket formula applied without regard to site context.

The policy also fails to adequately recognise existing open space provision or consider whether additional open space is necessary in all circumstances. Some employment schemes have been masterplanned to incorporate significant areas of green infrastructure and open space from the outset. Requiring each individual development to provide further open space does not reflect the campus-wide approach to open space provision and management already in place.

Furthermore, the policy does not sufficiently recognise the range of open space solutions that may be appropriate in commercial environments including roof terraces, roof gardens, courtyards and other forms of amenity space that can contribute to employee wellbeing and reduce any impact to nearby public open spaces arising from new commercial floorspace without unduly compromising the efficient use of development land.

The policy also provides limited clarity on how the requirement would apply to phased developments or future phases within larger employment campuses. This creates uncertainty for applicants and makes site planning, masterplanning and viability assessments more challenging.

The cumulative effect of these requirements risks placing an unnecessary burden on commercial development, contrary to the objective of supporting sustainable economic growth across Greater Cambridge.

Please provide your comments below (100 words max) (give details of why you consider the plan is not legally compliant or is unsound.)
Railpen supports the objective of providing and enhancing open space but considers the policy overly prescriptive for commercial development. Requiring schemes above 2,000 sqm GIA to provide 2 hectares of open space per 1,000 employees may constrain efficient land use and viability, particularly in urban locations. The policy insufficiently acknowledges existing provision, or alternative forms of amenity space including roof terraces, gardens and courtyards. It also lacks clarity for phased developments. Overall, the requirements risk placing unnecessary burdens on employment growth across Greater Cambridge.

Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:
Railpen recommends the removal of part 4 of the policy.